ALDABA vs. CA- Donation

A letter showing an intention to donate is not sufficient to prove donation; and most certainly not the form required by law in donations.


Two lots owned by Belen Aldaba are being disputed in this case. Petitoners Dr. Vicente Aldaba and Jane Aldaba, father and daughter, lived with Belen Aldaba for 10 years and took care of her until her death. Belen had presumptive heirs her surviving husband Estanislao Bautista, and her brother Cesar Aldaba (represented as the respondents in this case.) After the death of Belen, the respondents asked the petitioners to leave the premises and upon their refusal, the former instituted an ejectment case. The petitioners argue that Belen really intended to donate the property to them as evidence by the note written by Belen to them which reads, ―Huag kayong umalis diyan. Talagang iyan ay para sa inyo. Alam nila na iyan ay sa inyo.‖ They also argue that the property was for compensation of their services which amounted to P53,000. The respondents contend that the letter no way proves a donation.


Whether or not there was a disposition of property by Belen in favour of the petitioners?


For the following reasons: (1) The note was insufficient conveyance, and hence could not be considered as evidence of a donation with onerous caus. The note can be considered, at most, as indicative of the intention to donate. (2) no notarial document was executed by Belen to the petitioners during those 10 years. (3) P53,000 worth of services made by the petitioners no way proves the alleged donation. If at all, the petitioners believed that the gratuitous use of the property was not sufficient to compensate them for their services, they could have presented their claims in the intestate proceedings, which they themselves could have initiated, if none was instituted.

The SC emphasized that there was no express agreement between the parties and that respondents Jane did not even expect to be compensated.